BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Comments: Automated Clearing House (ACH) transactions — Request list responses indicate that the Bank has two ACH origination customers. Both are for payroll processing. ACH Monitoring — Request list responses indicate that CEO/CFO and BSA Officer monitor ACH activity International Automated Clearing House Transactions (IATs) — The Bank does not originate IATs. NOTE: The requested IAT reports were not provided.

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